Tax InterpretationsJudicial and CRA interpretations of Canadian tax law and transactional implications

Cases

Bastion Management Ltd. v. The Queen, 95 DTC 5238 (FCA)

Before finding that the inventory allowance was not available to a commodities future trader who purchased bullion shortly before its year-end on a hedged basis, then reversed its position immediately after its year-end, Linden J.A. stated (p. 5241):

"The provision was not enacted as an incentive for taxpayers to arrange their affairs so as to gain a tax benefit, but to aid those whose affairs had already been arranged in a particular way that led to an unfair tax disadvantage."